Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

During the COVID-19 pandemic, a county employer required its employees to either be fully vaccinated or undergo weekly COVID-19 testing. Employees could test at county facilities during work hours or use at-home test kits and count that time as work. Two employees objected to these requirements on religious grounds. One employee, Borgheiinck, asserted that mandatory vaccines and testing conflicted with her Christian beliefs about bodily autonomy. She was initially given unpaid leave as an accommodation, but the county later revoked this, citing undue hardship, and ultimately terminated her after not responding to her proposals for alternative work arrangements. The other employee, Colson, also objected on religious grounds. She was granted an exemption from nasal swab testing and allowed to use saliva tests, which she found intrusive and non-private, but she was not terminated.The United States District Court for the District of Minnesota dismissed all claims, including those under Title VII. The plaintiffs sought leave to file a motion for reconsideration based on new legal precedent, but the court denied this request. The plaintiffs appealed the dismissal of their Title VII claims and the denial of reconsideration.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. It held that Borgheiinck’s complaint did not sufficiently connect her religious beliefs to an objection to the testing policy, as required to state a plausible claim under Title VII. For Colson, the court held that she had not plausibly alleged that she suffered any adverse employment action, such as termination or unpaid testing time, since the county’s policy allowed testing during compensated time. The Eighth Circuit affirmed the district court’s dismissal of the Title VII claims and its denial of leave to seek reconsideration. View "Colson v. Hennepin County" on Justia Law

After protests in Des Moines, Iowa, escalated into rioting and looting at a mall in late May 2020, law enforcement was deployed to restore order and clear the area. A special police team, including Deputy Jason Tart, was authorized to use less-lethal munitions such as impact rounds. Monica Perkins, who had attended a vigil elsewhere, arrived near the mall area with her daughter. After an argument between Perkins and another driver on a nearby road, Deputy Tart fired an impact round that struck Perkins in her hand, injuring her. Perkins sued the City, various police officials, and Deputy Tart, alleging constitutional violations including excessive force and failure to intervene.The United States District Court for the Southern District of Iowa granted summary judgment to all defendants on every claim. The district court found that Perkins was not “seized” within the meaning of the Fourth Amendment, and even if she had been, Deputy Tart was entitled to qualified immunity. The court also held that Deputy Tart’s conduct did not amount to a substantive due process violation and that, because there was no underlying constitutional violation, the failure-to-intervene claim against other officers could not stand.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The Eighth Circuit agreed with the district court, holding that Deputy Tart’s actions did not objectively manifest an intent to restrain Perkins and thus did not constitute a seizure under the Fourth Amendment. The court further found no evidence that Deputy Tart’s conduct was conscience-shocking under the Fourteenth Amendment and concluded he was entitled to qualified immunity. As a result, the failure-to-intervene claim against the other officers also failed. The Eighth Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Perkins v. City of Des Moines" on Justia Law

Police officers in Des Moines executed an arrest warrant for Tyrone Cameron, who was wanted for First-Degree Murder and had a history of violent crime. Officers surrounded a house where Cameron was hiding, and one officer brought a trained canine, Bero. When Cameron was spotted attempting to flee by jumping from the roof, Officer Meunsaveng released Bero without giving Cameron a warning. Bero caught Cameron, who did not resist further or reach for weapons as officers handcuffed him. After Cameron was secured, Officer Meunsaveng removed Bero. Cameron later sued the City of Des Moines, Officer Meunsaveng, and other officers, alleging excessive force under 42 U.S.C. § 1983 and related tort claims under Iowa law.The United States District Court for the Southern District of Iowa granted summary judgment to all defendants. It found that Officer Meunsaveng did not use excessive force and had not violated any clearly established rights. As a result, claims against other officers for failing to intervene, as well as claims against the police chief and the City for failure to train, were denied. The district court also dismissed Cameron’s common law tort claims, reasoning that the absence of excessive force under federal law meant those claims could not succeed.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Cameron raised a genuine dispute of material fact as to whether Officer Meunsaveng violated a clearly established right by failing to warn before releasing Bero. The court reversed summary judgment on this claim. On all other claims—including the use of Bero to hold Cameron and the method of removing Bero—the court affirmed summary judgment for the defendants. The court remanded the Iowa common law tort claims to the district court for further consideration. View "Cameron v. City of Des Moines" on Justia Law

The plaintiff, an inmate in an Arkansas correctional facility, was placed in isolation for approximately six weeks during the summer, in a cell lacking air conditioning. He claimed that, as a dialysis patient subject to fluid restrictions, exposure to excessive heat caused him significant discomfort and posed a risk to his health. Throughout his confinement, he submitted several grievances to prison officials, asserting that his medical condition required air-conditioned housing. Although medical staff and other personnel were consulted, no documented medical restriction indicated that air conditioning was medically necessary for him, and prison officials relied on a physician’s opinion that his situation did not constitute an emergency.After discovery, the plaintiff brought a civil rights action under 42 U.S.C. § 1983 against three prison officials, alleging cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The United States District Court for the Western District of Arkansas granted summary judgment in favor of the defendants, finding them entitled to qualified immunity. The plaintiff’s motion for reconsideration was denied.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court assumed, for purposes of analysis, that the plaintiff’s medical condition presented an objectively serious risk. However, the court concluded that the record lacked evidence of deliberate indifference by the defendants: they consulted medical professionals, responded to grievances, implemented measures to mitigate heat, and treated the plaintiff’s medical complaints. Because the defendants did not violate a clearly established constitutional right, they were entitled to qualified immunity. The Eighth Circuit affirmed the district court’s judgment, holding that the prison officials were not deliberately indifferent to the plaintiff’s serious medical needs and did not subject him to cruel and unusual punishment. View "Hamilton v. Earl" on Justia Law

Donald Stephens was employed as an operator for United States Environmental Services, LLC, a position that required him to maintain a valid commercial driver's license (CDL). During a Saturday shift, Stephens refused to perform tasks typically assigned to technicians and raised several safety concerns, including inadequate equipment and staff. He also disclosed a heart condition to his supervisor. As a result, he was required to undergo a medical examination, which led to a 45-day medical hold on his CDL. Although he was medically cleared to perform non-driving work, USES denied his request for reassignment and recommended he seek short-term disability. After the hold was lifted and he was cleared to drive, Stephens resigned, claiming discomfort with his treatment by USES. Stephens filed suit in the United States District Court for the Eastern District of Arkansas, alleging disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Arkansas Civil Rights Act, as well as violations of the Fair Labor Standards Act (FLSA). The district court dismissed the FLSA claim and granted summary judgment to USES on the remaining claims. The court held that Stephens did not have a disability as defined by the ADA because his heart condition did not substantially limit a major life activity, and that USES did not regard him as disabled. The court also found that Stephens had not engaged in protected activity necessary to support a retaliation claim. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court affirmed the district court’s judgment, holding that Stephens did not demonstrate a substantial limitation of a major life activity and did not establish that he engaged in protected activity under the ADA. The Eighth Circuit also declined to consider an argument Stephens raised for the first time on appeal. View "Stephens v. U.S. Environmental Services LLC" on Justia Law

Deputy Brian Williams responded to a domestic-violence call at Tina Hight’s residence, where two dogs ran out toward him as Hight opened her door. Williams shouted warnings and fired a shot that caused the dogs to retreat. As Hight attempted to bring her dogs inside, a small Pomeranian mix ran toward Williams, prompting him to fire again in the dog’s direction. The shot missed the dog but ricocheted and struck Hight, leaving a bullet fragment in her leg.Hight filed suit in the United States District Court for the Western District of Arkansas, alleging excessive force under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. The district court granted summary judgment to Deputy Williams on the basis of qualified immunity, concluding that Williams did not violate Hight’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo, making all reasonable inferences in favor of Hight. The appellate court considered whether Deputy Williams’s actions constituted a Fourth Amendment seizure of Hight. Applying the requirement that a seizure by force must involve an officer’s objectively manifested intent to restrain the person affected, the court found no evidence that Williams intended to restrain Hight; his actions and statements were aimed at stopping the dog. The court held that accidental force, or force directed at another target, does not satisfy the Fourth Amendment’s seizure standard as articulated in Torres v. Madrid and related precedents.The Eighth Circuit affirmed the district court’s judgment, holding that Deputy Williams did not seize Hight within the meaning of the Fourth Amendment and thus did not violate her constitutional rights. The court declined to address arguments raised for the first time on appeal. View "Hight v. Williams" on Justia Law

On December 25, 2019, a patrol sergeant noticed a van idling in a driveway, twice encountered it, and approached the vehicle. The driver, Raymond Kelley, identified himself and his residence. The sergeant observed signs of alcohol and learned Kelley had a prior DUI and an active warrant. Kelley exited, was patted down, and sat on a wall; after asking to call his wife and being denied, Kelley ran up the driveway. The sergeant pursued and tackled Kelley, gaining control of his wrist. A deputy arrived after Kelley was tackled and assisted with handcuffing. Kelley complained of an arm injury, received medical attention, and was cited for public intoxication and resisting law enforcement before being released. Disputed facts center on the degree of Kelley’s resistance and the force used during handcuffing.Kelley sued under 42 U.S.C. § 1983, alleging unlawful arrest and excessive force against the officers in both their official and individual capacities. The United States District Court for the Eastern District of Arkansas granted summary judgment to the officers on the false arrest claim and on all claims against them in their official capacities. However, the court denied qualified immunity to both officers on the excessive force claim in their individual capacities, finding that disputed facts about Kelley’s conduct and the techniques used precluded summary judgment and should be resolved by a jury.Reviewing this interlocutory appeal, the United States Court of Appeals for the Eighth Circuit determined that the district court erred by failing to construe disputed facts in the light most favorable to Kelley and by not completing the required two-prong qualified immunity analysis. The Eighth Circuit vacated the district court’s order denying qualified immunity and remanded the case for a more detailed assessment, instructing the district court to consider both prongs of the qualified immunity analysis after properly construing the facts. View "Kelley v. Pruett" on Justia Law

A group of patients civilly committed under Minnesota law challenged the state's sex offender treatment program, alleging inadequate treatment and unconstitutional conditions of confinement. The lawsuit was brought as a class action, initially filed pro se and later supported by counsel through the Minnesota Federal Bar Association’s Pro Se Project. During the litigation, the patients, citing indigence and the need for expert testimony, requested court-appointed experts under Federal Rule of Evidence 706. Both parties jointly nominated experts, and in 2013, they recommended a 50/50 split of expert costs. However, the court initially allocated all costs to the defendants, reserving the option to adjust later.After more than a decade of litigation, the United States District Court for the District of Minnesota ruled in favor of the state officials on all claims. The officials then sought to recover litigation costs, including expert fees, as prevailing parties under Federal Rule of Civil Procedure 54(d)(1). The district court declined to award any costs to the officials, citing the plaintiffs' indigence, good faith, public importance of the issues, vigorous litigation, difficulty and closeness of the issues, and potential chilling effect on future litigants.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court failed to consider the plaintiffs’ 2013 recommendation to share expert costs and did not adequately weigh their acknowledged ability to pay half at that time. The Eighth Circuit vacated the district court’s cost judgment and remanded with instructions to award half of the expert costs to the prevailing defendants, to be assessed jointly and severally against the named plaintiffs. View "Karsjens v. Gandhi" on Justia Law

Two individuals were charged with multiple criminal offenses following an encounter with law enforcement. The initial police contact arose when an officer observed their vehicle driving at night without a functioning license plate light. After the officer followed the vehicle, one passenger exited and ran away, prompting further investigation. The officer questioned the driver, who admitted to having a suspended license and denied ownership of the car. Other officers arrived, and both individuals were eventually detained and handcuffed. A search of the vehicle revealed marijuana, methamphetamine, drug paraphernalia, and identification for the passenger. Subsequent criminal charges against both individuals were dismissed after a state court granted their motions to suppress the evidence.After the dismissal of the state charges, the two individuals filed a civil suit in the United States District Court for the Southern District of Iowa. They brought claims under 42 U.S.C. § 1983, alleging violations of their Fourth Amendment rights, and asserted additional claims under state law. The district court granted summary judgment in favor of the defendants—local officers and government entities—concluding that the officers were entitled to qualified immunity on the federal claims. The court also declined to exercise supplemental jurisdiction over some state law claims.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred in granting summary judgment on the federal claims against two officers. The Eighth Circuit held that the officers had, at minimum, arguable reasonable suspicion to justify the initial detention, that the warrantless search of the vehicle was permissible under the plain view doctrine, and that the arrests were supported by probable cause or, at least, arguable probable cause. The appellate court affirmed the district court’s judgment, upholding the grant of summary judgment in favor of the defendants. View "Valdivia v. Porsch" on Justia Law

Jay and Kendall Nygard, who have had a long history of disputes with the City of Orono regarding property matters, became involved in a conflict when Jay replaced their driveway without obtaining a permit as required by city code. Throughout the permitting process and subsequent communications with the City, Kendall was copied on email exchanges but did not perform the driveway work herself. After efforts by city officials to secure compliance failed, both Jay and Kendall were referred for prosecution for violating the permit requirement. However, a state court later dismissed the charge against Kendall, finding that the ordinance required only the person actually performing the work to obtain the permit, and Jay, not Kendall, had done the work.Following this dismissal, Kendall and Jay brought federal claims against the City, including a malicious prosecution claim. The United States District Court for the District of Minnesota dismissed all claims, but on appeal, the United States Court of Appeals for the Eighth Circuit allowed Kendall’s malicious prosecution claim to proceed, finding her complaint sufficiently alleged the City lacked probable cause. On remand, the district court declined to exercise pendent jurisdiction. Kendall then filed a new malicious prosecution claim based on diversity jurisdiction, but the district court again granted summary judgment to the City, concluding Kendall could not prove the City acted with malicious intent.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s grant of summary judgment. The court held that Kendall failed to offer evidence that the City knowingly and willfully instituted a groundless prosecution against her, as required to establish malicious intent under Minnesota law. The court found that, even if probable cause was lacking, there was no evidence of malice, and that any deficiency in probable cause was not so blatant as to permit an inference of malicious intent. The judgment in favor of the City was therefore affirmed. View "Nygard v. City of Orono" on Justia Law